1. SUMMARY OF PRIVACY POLICY

Commitment. We are committed to protecting your privacy.

The Information That You Provide Us. If you use the Services, we will need your Personal Information (such as your name, address, gender, age telephone number, e-mail address, networks, activities, and interests).

The Information We Collect. We may collect Personal Information about you from other Yotpo users, and anonymous and aggregate information. We also automatically collect Personal Information through your use of our Site and Services such as your IP address, device model and device ID. We also collect and retain your submitted reviews, which will include any Personal Information therein.

How We Use Your Information. We use your Personal Information in order to provide you with the best possible use of the Site and the Services, to maintain them, improve them and in order to protect us and the Services from misuse and law violations.

Disclosure of Your Information to Third Parties. A merger, acquisition or any other structural change may require us to transfer your Personal Information to other entities. In addition, we may transfer your Personal Information to any third party who assist us in connection with the Services, so long as those parties agree to keep your Personal Information confidential. Our customers on who’s website or platform you use the Services will also have access to your Personal Information. For more information about how they collect and process Personal Information please see their privacy policy on their website. We may be required by law to disclose information to the authorities.

Processing and Transfer of Your Information. Your Personal Information may be stored and processed in any country in which we or our affiliates, subsidiaries or agents maintain facilities. Transfers of your Personal Information outside the EEA will comply with applicable laws.

Security. We implement technical and organizational measures to secure your Personal Information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of your Personal Information.

Cookies and Other Tracking Mechanisms. We use cookies and other tracking mechanisms to track your activities on our Site and to compile statistics about your usage of our Site. We may also use third party analytics tools. Our Services do not respond to Do Not Track signals.

Your Rights. At any time, you may contact us and request to exercise your rights in accordance with applicable law. For more details see Section 12 below.

Opting Out of Receiving Marketing Communications From Us. At any time, you may opt-out from receiving marketing communications from us.

SOC 2 Compliance. Yotpo has undergone an audit to ensure compliance with SOC 2 standards for security, availability, and confidentiality.

US and Swiss-US Privacy Shield. We comply with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, as set forth by the U.S. Department of Commerce.

Period During Which We Keep Your Personal Information. We retain your Personal Information as needed to provide the Services, and for lawful purposes.

Our Commitment to Children’s Privacy. We do not intend to collect Personal Information from anyone we know to be under 16 years old. If you believe that we might have collected such information, please contact us.

2. OUR COMMITMENT TO PRIVACY

Your privacy is important to us. To better protect your privacy, we, Yotpo, Ltd. and our affiliates and subsidiaries (collectively, “Yotpo”, “we”, “us”, or “our”), provide this Privacy Policy explaining how we collect, use, and disclose Information (defined below) that we obtain about visitors to our website (www.yotpo.com) (the “Site”) and the services available through our Site (the “Services”). We also explain the choices you (“your” or “user”) can make about the way your Information is collected and used through our Site or Services.

3. GENERAL

You are not legally required to provide us with Personal Information, however, some of the Services require you to do so pursuant to this Privacy Policy. In these cases, if you choose to withhold any Personal Information requested by us, it may not be possible for you to access certain Services. By visiting our Site, or using our Services, you expressly consent that any information that we collect from or about you directly through this website, including Personal Information, anonymous information, and aggregate information (collectively, “Information”), will be handled as described in this Privacy Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. Our Terms of Service are incorporated by reference into this Privacy Policy.

We define “Personal Information” to mean any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We may update this Privacy Policy from time to time, at our sole discretion. We will notify you about significant changes in the way we treat Personal Information by sending a notice to the primary email address specified in your account and/or by placing a notice on the Site.

In the event an incentive plan is in effect, you may receive coupons as an incentive to submit reviews and share content. In this case, our systems will automatically grant you the coupon.

We optimize our email delivery process by calculating the optimal time to send you our emails, so that they are sent to you when you are likely to be available online and able to submit a review. The optimization engine is based on your online shopping and activities pattern.

4. SCOPE

We act as a service provider to operators of other websites and applications to help them drive customer reviews. To the extent that we collect Information – which may include your name, e-address, purchase information, and information from social media – about you on behalf of a customer, that Information is subject to that customer’s privacy policy. We are not responsible for the privacy practices of websites or applications that are operated or owned by third parties, even if they are linked from and/or through the Site or Services. The information practices of such third-party websites or applications is governed by the privacy policies of those third-party websites or applications.

5. HOW TO CONTACT US

If you have any questions about this Privacy Policy or our compliance with it, we encourage you to contact us at 33 West 19th Street, 5th Floor, New York, NY 10011 or privacy@yotpo.com.You are also welcome to contact our data protection officer at dpo@yotpo.com.

6. THE INFORMATION WE COLLECT

Information We Collect Directly from You. We may collect Information directly from you. For example, we may collect Information such as your full name, address, gender, age, telephone number, e-mail address, networks, activities and interests.

Information We Collect from Third Parties. During the registration process and/or otherwise while using the Site, we may give you the opportunity, in order to enhance your user experience, to share Information about your friends, colleagues, etc. in other platforms (such as social networks). We therefore may collect Information from other Yotpo users, such as when a friend of yours provides details about you, or indicates that you are in his/her network.

Information Automatically Collected About You. We also automatically collect Information through your use of our Site and Services using cookies and other technologies. This Information may include, without limitation, information about your operating system, settings and system configurations, IP address, device model, device ID and other unique device identifiers, the webpages you access within our Site, the website that led you to our Site, the website to which you go after leaving our Site, the dates and times you access our Site, and web log data.

7. HOW WE USE YOUR INFORMATION

Our primary purpose in collecting Information is to provide you with the products and services you or our customers request and those which we believe will optimize your use of the Site and Services, or our customers’ use of our services. In addition, you agree that we may use your Information, including Personal Information, for the following purposes:

1. To personalize your experience (your Information helps us to better respond to your individual needs).2. To analyze and improve our Site and Services (we continually strive to improve our Site and product offerings based on the Information and feedback we receive from you).3. To improve customer service (your Information helps us to more effectively respond to your customer service requests and support needs).4. To process transactions and orders you make through or in connection with the Site and registration thereto. Your Information, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than to our customers whose website or platform you use through the Services.5. To administer a contest, promotion, survey or other Site feature.6. To send periodic e-mails, updates, newsletters, and special offers, and for other marketing or advertising purposes.7. If you decide to opt-in to our mailing list, you will receive e-mails that may include company news, updates, related product or service information, etc.8. To comply with applicable legal obligations, including responding to informal requests for information from governmental authorities, and to prevent activity we determine to be potentially illegal.9. For the enforcement of this Privacy Policy and/or our Terms of Service or any other purpose referenced herein or therein, including to protect the rights of our customers, their end users, and the general public.

We may also use Information that has been de-identified and/or aggregated for purposes not otherwise listed above.

8. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

We do not sell, trade, or otherwise transfer to outside parties your Personal Information without your consent or as otherwise specified in this Privacy Policy. This does not include trusted third parties who assist us in operating the Site, conducting our business, servicing you in connection with the foregoing, or otherwise serve us or perform functions on our behalf, so long as those parties agree to keep this information confidential. We may also release your Information to current or future affiliates, parent companies, or subsidiaries. If we are acquired by or merged with another company, if we sell or transfer a business unit or assets to another company, as part of a bankruptcy proceeding, or as part of any other similar business transfer we may also disclose your Information. Additionally, we will disclose your Information when we believe release is appropriate to comply with the law, enforce our Site policies, or protect ours or others’ rights, property, or safety. However, we may disclose de-identified and/or aggregated Information to other parties for marketing, advertising, or other uses. Our customers on who’s website or platform you use through the Services will also have access to your Personal Information. For more information about how they collect and process Personal Information. Please see their privacy policy on their website. We require each of them to collect and process Personal Information lawfully and to obtain your consent where required.

9. PROCESSING AND TRANSFER OF YOUR INFORMATION

Your Information will be collected, processed, stored and used by us, and if/when applicable may be passed to and processed by our subsidiaries and/or affiliated companies. Information contributed by or collected from users may be stored and processed in any country in which we or our affiliates, subsidiaries or agents maintain facilities which may be outside of the European Economic Area. If there is a transfer of your Personal Information outside the EEA we will, in the absence of an EC Adequacy decision relevant to the destination country or to the transfer, seek to rely on appropriate safeguards such as a valid Privacy Shield certification (in the case of a data transfer to a Privacy Shield certified US recipient): https://www.privacyshield.gov/welcome), or enter into appropriate EC approved standard contractual clauses (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm). By using the Site or Services, you acknowledge and agree that you may be transferring your Information, including Personal Information, outside of the country in which you have contributed it, and that you consent to any such transfer of information outside of your country to a country that may not offer the same level of protection for Information as the country in which you reside.

PRIVACY SHIELD NOTICE

We comply with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the transfer of Personal Information from the EU and Switzerland to the U.S. For purposes of this Privacy Shield Notice, “Personal Information” includes information that identifies, directly or indirectly, a client or consumer in the EU or Switzerland. Yotpo has self-certified to the U.S. Department of Commerce and declared its commitment to adhere to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability (the “Principles”).

We encourage EU and Swiss individuals who have questions or complaints about how we process their Personal Information under Privacy Shield to contact us atprivacy@yotpo.com. We will work to resolve your issue as quickly as possible, but in any event within 45 days of receipt. If you have an unresolved privacy or data use complaints that we have not addressed satisfactorily, please contact, free of charge, our dispute resolution provider, JAMS, athttps://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim. If you are an EU or Swiss individual and unable to resolve any complaints through any of the above methods, you may be able to invoke binding arbitration through a Privacy Shield panel, in accordance with the Privacy Shield Framework athttps://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.

10. SECURITY

We take technical and organizational measures to guard against unauthorized or unlawful processing of your Personal Information and against accidental loss or destruction of, or damage to, your Personal Information. However, in order to protect your privacy we urge you: (1) to protect against unauthorized access to your use of the Site; (2) to ensure no one else uses the Site while the user’s machine is “logged on” to the Site; (3) to log off or exit from the Site when not using it; and (4) where relevant, to keep your password or other access information secret. We do not store credit card numbers or related identifying information on any Site server.

11. COOKIES AND OTHER TRACKING MECHANISMS

Cookies. We or our service providers may use cookies to track visitor activity on our Site. A cookie is a text file that a website transfers to your computer’s hard drive for record-keeping purposes. We or our service providers may use cookies to track user activities on our Site, such as the pages visited and time spent on our Site. Most browsers allow users to refuse cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies may not be able to browse certain areas of the Site.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages. We or our service providers may use clear GIFs (also known as web beacons, web bugs or pixel tags), in connection with our Site to track the activities of visitors to our Site, help us manage content, and compile statistics about usage of our Site. We or our service providers may also use clear GIFs in HTML emails to our users, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Do Not Track. Our Site may not respond to Do Not Track signals and we may track your activities once you leave our Site. You may disable certain tracking as discussed in this section (e.g., by disabling cookies).

Third-Party Analytics. We use service providers, such as Google Analytics, to evaluate the use of our Site and Services. We or our service providers use automated devices and applications to evaluate use of our Site and Services. We or our service providers use these tools to help us improve our Site, Services, performance, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or Flash LSO, to perform their services. For more information about how Google Analytics it collects and processes data see www.google.com/policies/privacy/partners/.

12. YOUR RIGHTS

Right of Access and Rectification. You have the right to know what Personal Information we collect about you and to ensure that such data is accurate and relevant for the purposes for which Yotpo collected it. We allow our users the option to access and obtain a copy of their Personal Information and to rectify such Personal Information if it is not accurate, complete or updated. However we may first ask you to provide us certain credentials to permit us to identify your Personal Information.

Right to Delete Personal Information or Restrict Processing. You have the right to delete your Personal Information or restrict its processing. We may postpone or deny your request if your Personal Information is in current use for the purposes for which it was collected or for other legitimate purposes such as compliance with legal obligations.

Right to Withdraw Consent. You have the right to withdraw your consent to the processing of your Personal Information. Exercising this right will not affect the lawfulness of processing your Personal Information based on your consent before its withdrawal.

Right of Data Portability. Where technically feasible, you have the right to ask to transfer your Personal Information in accordance with your right to data portability. The Reviews (as defined in our Terms of Service) are owned, by default, by the operator of the website and/or platform who you are engaged with through the Services. Therefore, In order to exercise your right to data portability in connection with the Reviews please contact the operator.

You may exercise the above rights by creating a request ticket in Yotpo’s support ticketing system.

If you have any questions or concerns regarding your rights, please contact our DPO at dpo@yotpo.com.

Right to Lodge Complaint. You also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your Personal Information.

13. OPT-OUT OF RECEIVING MARKETING COMMUNICATIONS FROM US

You may opt out of receiving marketing communications from us by contacting us at info@yotpo.com or following the opt-out instructions contained in the e-mail. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving e-mails about recommendations or other information we think may interest you, we may still send you e-mails about your account or responses to your inquiries.

15. U.S. AND SWISS-U.S. PRIVACY SHIELD

With respect to the Personal Information we receive from or on behalf of our clients and their customers in the EU and Switzerland, Yotpo, Inc. in the U.S. complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, as set forth by the U.S. Department of Commerce. You can review our Privacy Shield Notice at https://www.yotpo.com/privacy-shield.

16. PERIOD DURING WHICH WE KEEP YOUR PERSONAL INFORMATION

We will retain your Personal Information only as long as it is necessary for the purposes to which you consent under our terms and conditions and this Privacy Policy, or as is required by applicable law, and then we will delete it.

17. OUR COMMITMENT TO CHILDREN’S PRIVACY

Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain Personal Information on our Site or through our Services from those we actually know are under 16, and no part of our Site is structured to attract anyone under that age. If we discover that a child under 16 has provided us with Personal Information, we will promptly delete such Personal Information from our systems.